On October 3, 2025, the Federal Revenue Service issued a Normative Instruction that updates the Brazilian global minimum taxation regime, aligning the framework with the OECD guidelines on the taxation of multinational enterprises, with particular reference to digital platform operators.
The new framework is an update of the previously established one, adopted back in 2024. New rules are fully aligned with the Global Anti-Base Erosion (GloBE) model, pillar two of the OECD agreement.
The new framework strengthens the tax authorities’ ability to tax the profits of multinational enterprises conducting business in Brazil. The “Instruction” will come into force in two phases:
- Parts of the provisions shall be applicable from January 1, 2025
- Other parts from 2026
The additional guidelines and explanatory notes shall be issued in this regard.
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